ERISA-First Circuit Holds That Failure To Include Time Period For Filing Suit Renders The Plan’s Own Limitation’s Period Inapplicable

In Santana-Diaz v. Metropolitan Life Ins. Co., No. 15-1273 (1st Cir. Mar. 14, 2016), Appellant Dionisio Santana-Díaz (“Santana-Díaz”) challenges the district court’s dismissal of his suit as time-barred, arguing that he is entitled to equitable tolling, in part because the plan administrator, Appellee Metropolitan Life Insurance Company (“MetLife”), failed to include the time period for filing suit in its denial of benefits letter.

The First Circuit Court of Appeals (the “Court”) held that ERISA requires a plan administrator in its denial of benefits letter to inform a claimant of not only his right to bring a civil action, but also the plan-imposed time limit for doing so. Because MetLife violated this regulatory obligation, the plan’s limitations period in this case was rendered inapplicable, and Santana-Díaz’s suit was therefore timely filed. Accordingly, the Court reversed and remanded the case.

The Court said the following about the statute of limitations. ERISA itself does not contain a statute of limitations for bringing a civil action, so federal courts usually borrow the most closely analogous statute of limitations in the forum state. But where the employee benefit plan itself provides a shorter limitations period, that period will govern as long as it is reasonable. In this case, the plan contained a three-year limitations period that ran from the date proof of disability was due. MetLife included no mention of this time limit in its final denial letter. In failing to provide such notice, MetLife was not in substantial compliance with the ERISA regulations (see 29 C.F.R. § 2560.503-1(g)(1)(iv)) and that rendered the plan’s limitations period altogether inapplicable.

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